The Wealth Group 2009-2018

PRIVACY NOTICE

A.     Introduction

We are The Wealth Group Limited.  Our registered office is at 15 Queens Road, Evesham, WR11 4JN.  We are authorised and regulated by the Financial Conduct Authority with FRN 443827, authorised by the Information Commissioner as a data controller and processor with number Z9507563 and registered at Companies House in England and Wales with number 5073082.
 

This notice explains how we collect, use, disclose, transfer and store your “personal data”, by which we mean information that identifies you as an individual, or is capable of doing so. 
 

B.     Security measures

We take your privacy seriously.  We have implemented appropriate physical, technical and organisational security measures to secure your data against accidental loss, destruction or damage and unauthorised access, use, alteration or disclosure.  We will continue to collect, store, process and dispose of your personal data in line with data protection laws. Except as stated above, we will not disclose or transfer it to any third party for any purpose.

Unfortunately, the transmission of your personal data via the internet is not completely secure and although we do our best to protect it, we cannot guarantee the security of data transmitted to us over the internet and you acknowledge that any transmission is at your own risk.
 

C.     When we collect your data

This can happen throughout our relationship and be collected in meetings or when we deal with each other, e.g. by telephone, e-mail or post. We may collect data about you from fraud prevention agencies and others when we undertake checks such as identity verification.
 

D.     The types of data we collect and use

These include:

  • data about who you are and where you live, e.g. name, date of birth and contact details;

  • data about your personal, family, work, social and financial circumstances and plans, your attitude to risk and your capacity for loss;

  • any national identifier such as a national insurance number or tax reference;

  • data classified as ‘special category data’ (e.g. relating to your health, sex life, sexual orientation, ethnic or racial background, marital or civil partnership status), where it’s needed to provide the product or service you have requested or to comply with our legal obligations;

  • data you may provide us about other people e.g. joint applicants or beneficiaries for products you have asked us to arrange or review (NB Before you provide us with personal data relating to other people you should check that they are happy for you to share their data with us);

  • data on children e.g. where a child is named as a beneficiary on a policy taken out by a parent or guardian which you have asked us to arrange or review; 

  • data about your contact with us, eg meetings, phone calls, emails and letters; 

  • details of the services you request from us and which we provide to you;

  • records held by financial crime prevention agencies, on the Electoral Register and by providers of utility services.
     

E.     Why we hold your personal data and how we use it

We collect and use your data where it is in our legitimate interests to do so, ie so we can: (a) provide our initial and ongoing financial planning, investment advisory and estate planning services to you and generally ensure the suitability for your circumstances of advice we give and products we recommend; (b) keep records of our advice, research, transactions etc for reference in connection with future advice, to deal with queries or complaints and to allow us to prepare and file returns with our regulator and to prepare our accounts.  Examples of the uses to which we put your data are: 

  • completing identity checks for fraud prevention and anti-money laundering purposes

  • liaising with investment/pension/insurance providers to gather further information about your plans and policies so that we can advise you about them; 

  • producing an indicative investment attitude-to-risk profile and capacity-for-loss report using automated decision making via the Dynamic Planner computer program;

  • completing our “know your customer” process;

  • completing product and service application forms for you to review and sign;

  • arranging ISA and pension contributions and/or income and capital withdrawals; 

  • preparing investment valuation statements;

  • calculating fees due to us and matching receipts against your account as appropriate; 

  • maintaining the paper and computer-based records in which we hold your data;

  • answering your questions; 

  • providing data to any relevant regulatory authority or in respect of any court order.
     

We may share your data with others, for example:

  • companies who provide the financial products and services we may recommend to you;

  • your other professional advisers (e.g. accountants and solicitors) with your permission;

  • other professional advisers (e.g. mortgage advisers, solicitors and accountants) we recommend for services you require and where you do not have a retained adviser you wish to use;

  • your spouse, other family members etc with your permission;

  • our professional advisers: for example, as a quality control measure, we sometimes use external compliance consultants to check our files and advice;

  • our professional indemnity brokers and insurers in the event of a complaint or periodic review of business undertaken;

  • companies who provide us with all or any of: financial planning, product and risk analysis software; investment attitude-to-risk and capacity-for-loss software; back-office system software; business processing/communications software; data back-up and storage facilities;

  • the representatives of a potential buyer/partner if we wish to sell or merge part or all of our business or assets, provided they have first signed a confidentiality agreement with us;

  • our regulator and other authorities when required by law so to do;

  • to investigate or prevent fraud or other activities believed to be illegal. 

When we share data in this way, we will check that the third parties undertake to process your personal data in compliance with the law.
 

F.      Data retention

We are committed to keeping your personal data only for as long as necessary to fulfil the purposes for which it was collected and otherwise for as long as we are required or permitted to keep it by law.

We will retain the following for 7 years after the end of our contract with you: 

  • all advice-related records and data in respect of our contract with you, so we can deal with any legal issues arising from the contract; 

  • all data provided to us for identity checks, financial crime and anti-money laundering checks. 


We will retain the following indefinitely after the end of our contract with you:

  • all records of complaints and related data;

  • all records of pension transfers, pension conversions, pension opt-outs or free-standing additional voluntary contributions.
     

G.     Transferring data overseas

We may share your personal data with our service providers and this may involve transferring it to countries outside the European Economic Area (EEA). We will only do this on the basis that those countries provide a level of data protection equivalent to that within the EEA.
 

H.     Children

Children under the age of 13 are not permitted to use our services unless their parent/legal guardian provides verifiable consent.  If we learn that we have collected the personal data of a child under 13 without that consent, we will take steps to delete the information as soon as possible or obtain parental/legal guardian consent if appropriate.


I.      Your rights

You have the following rights, which can be exercised by contacting us at the address given below:

  • to be informed about our collection and use of your personal data (the detail of that collection and use is set out in sections D and E of this notice)

  • to obtain a copy of the personal data we hold about you (known as ‘subject access’);

  • to request the rectification or completion of personal data which are inaccurate or incomplete;

  • to request the restriction or suppression of your personal data;

  • to object to the processing of your personal data;

  • to be informed about any use of your personal data to make automated decisions about you and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and

  • if you give us your specific consent to process your special category data (for example data relating to health, race or ethnic origin), then you also have the right to data portability and the right to request erasure of your data.

If you would like to exercise any of your rights set out above, you can contact us at the address given below. When you contact us, we may ask you to provide additional information to verify your identity.

You also have the right to lodge a complaint with the Information Commissioner’s Office about the way in which we are using your personal data.  The contact address is: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
 

J.      Changes to this privacy notice

Any changes will be posted on our website at www.wealth-group.co.uk
 

K.     Contacting us

If you have any queries, comments or requests regarding this notice or you would like to exercise any of your rights set out above, please can contact our Compliance Officer in one of the following ways: